The “Last Seen” Doctrine: Shortcut to Justice or Path to Wrongful Conviction
The “last seen” doctrine, a principle of circumstantial evidence, holds that a person last seen in the company of a deceased victim bears a burden to explain the circumstances surrounding the victim’s death. While often used to secure convictions in the absence of direct evidence, this doctrine has raised serious concerns about fairness, evidential sufficiency, and the risk of wrongful convictions.
This paper looks closely at how courts in Nigeria have used the “last seen” rule in criminal trials. It also compares this with how other countries that follow similar legal systems use the same rule. The study asks whether this doctrine is a useful legal tool or a dangerous shortcut that puts too much pressure on the accused and weakens the rule that everyone is innocent until proven guilty.
The research employs a doctrinal methodology complemented by a case analysis approach, identifying cases where over-reliance on the doctrine led to miscarriages of justice. The paper ends by calling for stronger rules and more careful use of this doctrine in court, in order to be sure that justice is done and the rights of accused persons are protected.
Introduction
Definition of the ‘Last Seen’ Doctrine
The ‘last seen’ doctrine is a legal principle in criminal law which holds that when a person is last seen in the company of a deceased victim shortly before their death, and fails to provide a satisfactory explanation, the court may presume that the person is responsible for the victim’s death. This doctrine is typically applied in cases where there is no direct evidence linking the accused to the crime, and it forms part of the circumstantial evidence used to establish guilt. The application of this doctrine is particularly prevalent in homicide cases or disappearance, where circumstantial evidence plays a critical role in establishing guilt.
Overview of its Application in Nigerian Law
In Nigerian criminal jurisprudence, the Last Seen doctrine has become a significant evidentiary tool, especially in the prosecution of murder cases where direct evidence is lacking. Courts frequently invoke this doctrine in combination with Section 167(d) of the Evidence Act, which permits the court to presume that withheld evidence would be unfavourable to the accused. Though not formally codified, Nigerian appellate courts have affirmed the doctrine’s legitimacy through case law, often treating it as a persuasive basis for drawing inferences of guilt in the absence of contradictory evidence from the defendant.
Thesis Statement
This paper critically examines the operation of the ‘Last Seen’ doctrine in Nigeria, interrogating its reliability and fairness as a tool of justice. While it helps prosecutors in cases where there are no eyewitnesses or forensic evidence, the doctrine also poses a grave risk of wrongful convictions, particularly when courts overlook the weaknesses inherent in circumstantial reasoning. The central question is whether the doctrine represents a shortcut to justice or a pathway to injustice in Nigeria’s criminal justice system.
Legal Frameworks
A. Relevant Laws
The ‘Last seen’ doctrine originated from common law legal systems, particularly English common law, which forms the foundation of many legal traditions in countries like Nigeria, India, Canada, and the United States. While there’s no single case that marks the “birth” of the doctrine, the principle evolved through judicial interpretation over time.
It developed as a rule of circumstantial evidence where proof of facts surrounding a crime (not direct eyewitness testimony) is used to infer guilt. Below are some relevant statutory provisions from countries that have embraced this doctrine:
India: The Indian judiciary has extensively used the last seen theory. It is frequently invoked in murder trials and supported by Section 106 of the Indian Evidence Act which states that when a fact is especially within the knowledge of a person, the burden of proving that fact lies on them.
Nigeria: As a common law country, Nigeria inherited this doctrine through colonial legal influence. Nigerian courts apply it alongside provisions like Section 167(d) of the Evidence Act, which permits adverse inference where a party fails to provide evidence on a matter within their knowledge.
United Kingdom: The UK operates common law principles, and the “last seen” fact is treated as part of a chain of circumstantial evidence, which, when considered as a whole, may point to the accused’s guilt. The prosecution still bears the burden of proving the case beyond reasonable doubt. However, unexplained circumstances (such as being last seen with the deceased) may raise inferences if the totality of evidence supports it.
Section 106 of the Indian Evidence Act addresses situations where a fact is uniquely known to one party, typically the accused in a criminal case. In such instances, the burden shifts to that person to explain or prove that fact.
This section does not override the presumption of innocence or the general rule that the burden of proof lies on the prosecution. Rather, it creates an exception in circumstances where the accused is uniquely placed to explain something that the prosecution cannot reasonably be expected to know. In murder cases, when an accused is the last person seen with the deceased and the death occurs in suspicious circumstances shortly afterward, Section 106 is invoked to say:
“Since the accused was last seen with the deceased and the death occurred soon after, the burden lies on the accused to explain what happened during that time.”
This supports the inference under the Last Seen Doctrine, especially when the prosecution has established the surrounding facts.
Section 167(d) of the Evidence Act states that “The court may presume that evidence which could be and is not produced would, if produced, be unfavourable to the person who withholds it.” The interpretation of this statutory provision vis-à-vis the ‘last seen’ doctrine is that if the accused was last seen with the deceased and offers no explanation, the court may presume that his silence implies guilt.
B. Key Cases Illustrating the Application of the “Last Seen” Doctrine
1. Njovens v. The State (1973) 5 SC 17
🔹Facts:
The accused was the last person seen with the deceased, who was later found dead under suspicious circumstances.
🔹Decision:
The Supreme Court held that where an accused was last seen with the deceased and fails to give an explanation, the court is entitled to draw an inference that the accused was responsible for the death especially where the accused is silent or gives an ‘incredible’ explanation.
🔹Significance:
This case laid down the foundation of the ‘last seen’ principle in Nigerian jurisprudence.
2. Gabriel v. The State (1989) LPELR-SC.12/1988
🔹Facts:
The appellant was the last person seen with the deceased, a young girl, who was later found dead. His explanation was unconvincing.
🔹Decision:
The court affirmed that the ‘last seen’ doctrine was applicable, and that the accused’s failure to explain what happened was damning circumstantial evidence.
🔹Significance:
The case reinforced that being last seen with a deceased can, if unrefuted, support a conviction for murder.
3. Igabele v. The State (2006) 6 NWLR (Pt. 975) 100
🔹Facts:
The accused was last seen with the deceased, and no other person was known to be with them. The body of the deceased was discovered shortly after.
🔹Decision:
The Supreme Court held that the burden shifts to the accused to give a reasonable explanation. Failure to do so supports an inference of guilt based on circumstantial evidence.
🔹Significance:
This case clarified that the “last seen” principle does not shift the legal burden of proof but allows for reasonable inferences in the absence of explanation.
4. Okoro v. The State (2012) LPELR-9343(CA)
🔹Facts:
The deceased was last seen alive with the appellant. No direct evidence linked him to the murder, but circumstantial facts pointed in that direction.
🔹Decision:
The Court of Appeal affirmed that the accused’s silence or unsatisfactory explanation, when last seen with the victim, could ground a conviction.
🔹Significance:
The case confirms that the doctrine is valid even at the appellate level, provided the evidence forms a complete chain of circumstantial facts.
5. Edet v. The State (2008) 14 NWLR (Pt. 1106) 52
🔹Facts:
The accused was the last person seen with the deceased before his body was discovered.
🔹Decision:
The court emphasized that mere presence is not enough; the totality of circumstances must point clearly and irresistibly to guilt.
🔹Significance:
This case highlights the limits of the doctrine. Courts must avoid convicting solely based on presence unless there are additional incriminating factors.
✍🏽 Summary of Legal Position:
- The doctrine allows inferences of guilt from silence or false explanations when the accused was last seen with the deceased.
- However, the burden of proof remains on the prosecution.
- The accused must only offer a plausible explanation, not prove innocence.
3. The Rationale Behind the Last Seen Doctrine
A. Legal Justification for the Doctrine in Homicide Cases
The legal justification for the ‘Last Seen’ doctrine in homicide cases lies in the need to establish a connection between the accused and the act of killing. The doctrine operates under the premise that the last person seen with the deceased often has the best opportunity to explain the circumstances surrounding the death. This principle is rooted in the idea that if someone was present when the deceased was last known to be alive, their proximity implies a potential involvement in the subsequent events leading to the death.
B. The Presumption of Guilt Based on Proximity to the Deceased
The ‘Last Seen’ doctrine establishes a presumption of guilt where circumstantial evidence indicates that the accused was the last person seen with the deceased prior to their death. This presumption compels the accused to provide a satisfactory explanation regarding how the deceased met their end. The failure to do so can lead the courts to infer guilt, as demonstrated in various legal precedents.
C. Case Law Supporting the Rationale
Nigerian case law provides substantial support for the rationale behind the ‘Last Seen’ doctrine. In Nwaeze v. The State1, the Supreme Court reiterated that the doctrine serves as a critical tool for the prosecution, establishing a compelling link between the accused and the deceased. Additionally, in Ijeoma Anyasodor v. The State2, the Court acknowledged the applicability of the doctrine, asserting that “the law presumes that the person who was last seen with the deceased bears full responsibility for their death.” This judicial endorsement emphasizes the doctrine’s role in ensuring accountability and its function in the criminal justice system.
4. The Risks of Wrongful Convictions
The “Last Seen” doctrine, while a crucial tool in circumstantial evidence cases, carries inherent risks that can lead to wrongful convictions if not applied with extreme caution and robust corroboration. The doctrine is a prime example of reliance on circumstantial evidence, which, by its nature, requires careful scrutiny.
A. Issues with Reliance on Circumstantial Evidence
Inadequate Corroborative Evidence:
The Core Problem: The most significant risk associated with the “Last Seen” doctrine is when convictions are based solely or primarily on this circumstance without sufficient, independent corroborating evidence. While the doctrine creates a strong presumption, it is not direct proof of guilt. For instance, in Ijeoma Anyasodor v. The State supra, although the court ultimately upheld the conviction, it warned that circumstantial evidence must form a complete and unbroken chain pointing exclusively to the guilt of the accused. Where this is lacking, the risk of wrongful conviction becomes high.
“Gap in the Chain”: If the other links in the chain of circumstantial evidence are weak, speculative, or absent, relying heavily on the “Last Seen” fact can lead to a flawed conclusion. For instance, if there’s no motive, no weapon, no forensic link, and the accused’s explanation (even if not entirely convincing) isn’t definitively disproven, a conviction based primarily on “last seen” becomes highly precarious.
Possibility of Other Scenarios: Without strong corroboration, there remains a reasonable possibility that another individual intervened, that the death was accidental, or that the deceased went missing for other reasons after being last seen with the accused. The human imagination can conceive of many possibilities, and the prosecution’s burden is to exclude all reasonable ones except the guilt of the accused.
Time Gap Vulnerability: Even a seemingly short time gap can be exploited by an alibi, or the defence could argue that the time was sufficient for an unknown third party to commit the crime. Without additional evidence, the prosecution’s case can crumble.
Potential Biases in Witness Testimonies: Witnesses may unintentionally or deliberately misstate the time or context in which the accused was seen with the deceased. In Nwaeze v. The State supra, the Supreme Court reversed a conviction based on witness inconsistencies and emphasized that being last seen is not sufficient to establish guilt where reasonable doubt exists as to the time and cause of death. This demonstrates how flawed testimony can fatally affect the outcome of a case.
Memory Fallibility: Witness memory is notoriously unreliable, especially under stress or over time. A witness’s recollection of who was “last seen” with the victim, and the exact time and circumstances, can be genuinely mistaken.
Suggestibility and Confirmation Bias: Sometimes, what police or the news say can subtly influence people who saw things. If a witness hears that someone specific is suspected, their memory might unconsciously twist to fit that idea, even if they’re trying to be honest. They start remembering things in a way that supports the police’s theory, rather than exactly how it happened.
Motive to Fabricate: In some tragic cases, witnesses might have their own motives to implicate a particular individual, whether out of personal animosity, a desire to divert suspicion from themselves, or to protect another person.
Misidentification: While less common with the “Last Seen” doctrine (as it often involves known acquaintances), misidentification can still occur, especially if the sighting was fleeting or in poor conditions. A witness might genuinely believe they saw Person A, when in fact, it was Person B.
B. Notable Cases of Wrongful Convictions Linked to the ‘Last Seen’ Doctrine
While specific high-profile cases solely overturned on the “Last Seen” doctrine are less frequently highlighted than, say, DNA exonerations, its role in contributing to wrongful convictions is often an underlying factor in cases based on weak circumstantial evidence. Courts, especially higher appellate courts, are increasingly emphasizing the need for robust corroboration when the “Last Seen” doctrine is invoked.
Analysis of Specific Cases Where Individuals Were Wrongfully Convicted (Illustrative Examples and Principles):
Cases with Long Time Gaps: Many appeals where the “Last Seen” doctrine was a significant piece of evidence often highlight instances where there was an unexplained or extended time gap between the last sighting and the discovery of the body. If the prosecution fails to account for this gap with other evidence (e.g., that the accused was with the victim the whole time, or that the victim was deceased during the gap), the “last seen” inference loses its strength. Wrongful convictions can arise when trial courts fail to adequately consider this crucial aspect.
Lack of Forensic Link: Cases where individuals were convicted based on “last seen” but later found to be innocent often involve the absence of any forensic evidence connecting the accused to the crime scene or the victim’s death. This stark absence, especially in modern forensics, can be a strong indicator of a flawed conviction if “last seen” was the primary piece of evidence.
Later Discovery of an Alternative Perpetrator/Cause of Death: Some wrongful convictions are exposed when new evidence emerges pointing to another individual as the perpetrator, or when it’s determined the death was accidental or self-inflicted, completely undermining the premise of the “Last Seen” doctrine in that specific case. While not directly about the doctrine’s flawed application, it shows how reliance on it without thorough investigation can lead to miscarriages of justice.
Forced Confessions/False Explanations: Sometimes, individuals are pressured into providing false or misleading explanations (which can then be used against them in conjunction with the “last seen” theory), or even false confessions, due to intense interrogation. Later, when these are recanted or proven false, the “last seen” evidence, which initially seemed strong, becomes tainted.
Examination of Appeals and Reversals Based on the Doctrine:
Emphasis on “Complete Chain”: Appellate courts frequently reverse convictions if the “Last Seen” doctrine was relied upon without the prosecution establishing a “complete chain of circumstances” that points only to the guilt of the accused and excludes all other reasonable hypotheses. The Supreme Court of India, for instance, has repeatedly cautioned against sole reliance on this doctrine.
Insufficient Proof of Homicide: In some reversals, the appellate court found that while the “last seen” circumstance might have been proven, the prosecution failed to conclusively prove that the victim was homicidally killed, or that the accused was directly responsible for the death. If the cause of death remains ambiguous or could be accidental/natural, the “last seen” doctrine alone cannot establish guilt.
Reasonable Doubt from Time Gap/Lack of Corroboration: Many successful appeals argue that the time gap between the last sighting and the discovery of the body was too long, or that there was an absence of other crucial corroborating evidence (like motive, recovery of weapon, or forensic links) that would have solidified the “last seen” inference. The defence successfully creates “reasonable doubt” by highlighting these gaps.
The Reena Hazarika v State of Assam Principle: As mentioned previously, the Supreme Court of India in Reena Hazarika clarified that merely being last seen with the victim does not automatically shift the burden of proof to the accused to prove their innocence beyond all reasonable doubt. This case underscores that the prosecution still bears the primary burden, and the accused only needs to cast doubt. This principle has likely led to reversals where trial courts misapplied the burden of proof.
Reversals based on Section 106 Misapplication: Appeals often succeed when it’s argued that Section 106 of the Evidence Act (relating to facts especially within one’s knowledge) was misapplied. While the accused may have knowledge of the last interaction, this doesn’t equate to knowledge of the death or responsibility for it, particularly if the interaction was brief or
2. Examination of Appeals and Reversals Based on the Doctrine
Several appellate courts in Nigeria have reaffirmed that mere proximity, without a strong evidential foundation, cannot sustain a conviction. For example:
- In Orji v. The State3, the Supreme Court cautioned that the ‘last seen’ doctrine must not be used in isolation. The court emphasized that unless the circumstantial evidence clearly and irresistibly points to the accused, the doctrine can lead to injustice.
In summary, these cases confirm that while the ‘last seen’ doctrine can be useful, courts must apply it with great caution. Misapplication or over-reliance on this principle especially in the absence of corroborating evidence has led to wrongful convictions. Adequate corroboration, careful consideration of time gaps, scrutiny of witness testimonies, and adherence to the fundamental principle of proof beyond a reasonable doubt are paramount to ensure that justice is served and miscarriages avoided.
5. Comparative Analysis
Here’s a comparative analysis focusing on the “Last Seen” doctrine, international perspectives on wrongful convictions, and recommendations for reform, particularly with Nigeria in mind:
A. Examination of the ‘Last Seen’ Doctrine in Other Jurisdictions
While the “Last Seen” doctrine isn’t explicitly codified in many common law jurisdictions as a separate doctrine, the underlying principle of inferring guilt from proximity to the deceased is universally recognized as a form of circumstantial evidence.
- United Kingdom (UK):
- No explicit “last seen doctrine” but circumstantial evidence principles apply rigorously.
- Courts emphasize that circumstantial evidence must form a “compelling chain” that leaves no reasonable doubt as to the accused’s guilt.
- The prosecution bears a high burden to exclude all other reasonable inferences.
- The concept of a “recent opportunity” to commit the crime (similar to “last seen”) is a significant factor but always requires strong corroboration.
- Focus is on the overall strength of the prosecution’s case, not just one piece of circumstantial evidence.
- United States (US):
- Like the UK, there isn’t a specific “last seen doctrine” statute.
- “Last seen” is treated as powerful circumstantial evidence.
- Prosecutors often use it to establish opportunity and to rebut alibis.
- It’s rarely, if ever, sufficient for conviction on its own. It must be combined with other evidence such as motive, forensic evidence, confessions, or lack of credible alternative explanations from the accused.
- The “beyond a reasonable doubt” standard necessitates a complete and compelling case built on multiple pieces of evidence, even if circumstantial.
- Canada:
- The approach is like the UK and US. “Last seen” is a piece of circumstantial evidence.
- Canadian courts require that the inference of guilt must be the “only reasonable inference” available from the proven facts. If there’s another reasonable explanation, the benefit of the doubt goes to the accused.
- The case of R. v. W. (D.)4 by the Supreme Court of Canada is a foundational case emphasizing how a judge or jury should approach evidence, especially where credibility is an issue – if the accused’s explanation might reasonably be true, even if not fully believed, they must be acquitted.
- Australia:
Australian courts do not treat “last seen” as a distinct legal doctrine, but the fact that an accused was last seen with the deceased is often a critical part of the circumstantial evidence. It may contribute to an inference of guilt, but it must be considered with all other evidence. In R v Baden-Clay5, Gerard Baden-Clay was convicted of murdering his wife.
- He was last seen with her before she disappeared.
- The “last seen” factor was important, but the conviction rested on multiple pieces of circumstantial evidence, including forensic and behavioural evidence.
- India:
- As previously discussed, the “Last Seen” doctrine is frequently invoked, with reference to Section 106 of the Indian Evidence Act.
- Indian courts have provided extensive jurisprudence on its application, consistently emphasizing the need for:
- A short time gap between the last sighting and the death.
- The absence of a plausible explanation from the accused.
- Strong corroboration from other pieces of circumstantial evidence to form a complete chain.
- Cases like Reena Hazarika v. State of Assam6 have clarified that the doctrine does not automatically shift the burden of proof to the accused to prove innocence.
B. Lessons Learned from International Perspectives on Wrongful Convictions and Evidential Standards
International experience highlights critical lessons to prevent wrongful convictions, especially in cases relying on circumstantial evidence:
- Corroboration is King: The most consistent lesson is that no single piece of circumstantial evidence, including “last seen,” should ever be the sole basis for conviction. Multiple, independent pieces of evidence, all pointing towards guilt, are essential.
- Scrutiny of Time Gaps: Courts internationally are highly suspicious of long, unexplained time gaps between the last sighting and the discovery of the crime. Such gaps introduce too many possibilities for other actors or events.
- Cautious Application of Burden Shifting (or “Evidential Burden”): While the “last seen” doctrine might place an evidential burden on the accused to explain their presence, it never shifts the ultimate legal burden of proof from the prosecution to prove guilt beyond a reasonable doubt. Misunderstanding this distinction is a major cause of wrongful convictions.
- Reliability of Witness Testimony: International experience, particularly from innocence projects, consistently points to eyewitness misidentification and flawed witness testimony as leading causes of wrongful convictions. This underscores the need for:
- Scientific protocols for eyewitness identification: e.g., double-blind procedures, sequential lineups.
- Recording of interrogations: To prevent and expose coercive tactics and ensure accuracy of statements.
- Careful assessment of witness credibility: Including potential biases or motives.
- Exclusion of Other Hypotheses: A fundamental principle is that the circumstantial evidence must be inconsistent with any reasonable hypothesis other than the guilt of the accused. If any reasonable alternative explanation exists, an acquittal should be granted to the accused.
- Forensic Science Standards: While not directly about “last seen,” robust, independent, and peer-reviewed forensic science is crucial for corroboration. Flawed or misused forensic evidence has been a factor in many wrongful convictions globally.
- Access to Justice and Legal Aid: Adequate legal representation for the accused ensures that all possible defences are explored, and weaknesses in the prosecution’s circumstantial case are effectively highlighted.
C. Recommendations for Reform in Nigerian Law (Principles for Consideration)
Nigeria, as a common law jurisdiction, shares many principles with the UK, US, and Canada. However, strengthening certain aspects related to circumstantial evidence, especially the “Last Seen” doctrine, could further safeguard against wrongful convictions.
- Codification or Clear Judicial Guidelines on Corroboration:
- Recommendation: While judges currently require corroboration, explicit legislative or judicial guidelines (perhaps through a Supreme Court ruling clarifying the doctrine) could stipulate that “last seen” evidence, by itself, is insufficient for conviction.
- Benefit: Provides clarity for lower courts, ensures consistency, and reduces subjective interpretation.
- Emphasis on “Short Time Gap” and “Unexplained Circumstances”:
- Recommendation: Judicial pronouncements should strongly emphasize that the “last seen” inference is strongest only when there is a very short and unexplained time gap between the last sighting and the discovery of the deceased, leaving little room for third-party intervention. Long time gaps, without strong accompanying evidence, should significantly weaken the prosecution’s case.
- Benefit: Prevents over-reliance on a weak “last seen” link in the chain of evidence.
- Strict Adherence to “Beyond Reasonable Doubt” in Circumstantial Cases:
- Recommendation: Reiterate and rigorously apply the principle that in circumstantial cases, the evidence must point irresistibly and exclusively to the guilt of the accused, excluding every other reasonable hypothesis.
- Benefit: Upholds the high standard of proof required in criminal law, reducing convictions based on mere suspicion or probabilities.
- Training for Law Enforcement and Prosecutors on Circumstantial Evidence:
- Recommendation: Implement training programs for investigators and prosecutors on the proper collection, analysis, and presentation of circumstantial evidence, including the limitations of the “last seen” doctrine.
- Benefit: Improves the quality of investigations, builds stronger (or correctly abandoned) cases, and reduces reliance on problematic evidence.
- Enhanced Witness Interview Protocols:
- Recommendation: Adopt and enforce best practices for witness interviews, including:
- Recording all interviews (audio/video): Provides an objective record, deters leading questions, and helps assess voluntariness and accuracy.
- Avoiding suggestive questioning: Training interviewers to use open-ended questions.
- Awareness of confirmation bias: Investigators should be trained to avoid forming premature conclusions about suspects.
- Benefit: Increases the reliability of witness testimonies and reduces the risk of tainted evidence.
- Recommendation: Adopt and enforce best practices for witness interviews, including:
- Strengthening Forensic Capabilities and Standards:
- Recommendation: Invest in and develop robust, independent forensic science capabilities. Ensure that forensic evidence is collected, analysed, and presented according to international best practices.
- Benefit: Provides crucial corroboration (or exculpation) for circumstantial cases, moving beyond reliance on solely testimonial or proximity-based evidence.
- Robust Appeals Process and Post-Conviction Review:
- Recommendation: Ensure that the appeals process is effective in identifying and rectifying errors in legal reasoning or factual findings, particularly in cases based on circumstantial evidence. Consider mechanisms for post-conviction review for claims of actual innocence based on new evidence.
- Benefit: Provides a critical safeguard against miscarriages of justice, even after initial conviction.
By adopting these principles and recommendations, Nigerian law can strengthen its framework for circumstantial evidence, particularly concerning the “Last Seen” doctrine, thereby enhancing justice delivery and minimizing the risk of wrongful convictions.
References
Statutes
- Section 167(d) of the Evidence Act, 2011, Laws of the Federation of Nigeria 2004
- Section 106 of the Indian Evidence Act, 1872
Case law
- Edet v. The State (2008) 14 NWLR (Pt. 1106) 52
- Gabriel v. The State (1989) LPELR-SC.12/1988
- Ijeoma Anyasodor v. The State (2018) 8 NWLR (Pt. 1620) 107
- Igabele v. The State (2006) 6 NWLR (Pt. 975) 100
- Njovens v. The State (1973) 5 SC 17
- Nwaeze v. The State (1996) 2 SCNJ 47
- Okoro v. The State (2012) LPELR-9343(CA)
- Orji v. The State (2008) 2 NWLR (Pt. 1071) 518
- R v Baden-Clay [2016] HCA 35
- R. v. W. (D.) [1991] 1 S.C.R. 742
- Reena Hazarika v. State of Assam (2019) 13 SCC 289
About Author
Oluwayomi Morawo graduated from the faculty of law, University of Lagos in the year 2012 and the Nigerian Law School, Bwari, Abuja in the year 2013. Due to her interests in criminal law, she did a master’s program in Legal Criminology and Security Psychology and has authored a number of articles in the fields of criminal law and criminology.
Leave a Reply